17th Annual Tax Controversy Forum 2025 – Track I (Presented by NYU School of Professional Studies)

Kathleen Costello delivers opening remarks to set the stage for the two-day forum. Attendees receive an overview of the program structure and key themes to be explored.

This session examines the unprecedented upheaval at the IRS following significant leadership changes and workforce reductions of up to 26%. Panelists discuss the impact of resource constraints on tax enforcement and provide guidance for practitioners navigating the current environment.

Experts analyze the proposed 37% reduction in IRS funding and its implications for enforcement capabilities. The panel addresses OECD Pillar 2 developments, Section 899 implications, and the uncertain regulatory guidance outlook affecting tax certainty.

Chief Elizabeth Askey discusses Appeals’ projected 28% workforce reduction and its impact on dispute resolution. The session highlights ADR program improvements including 25% increased receipts and new Fast-Track availability on an issue-by-issue basis.

Judge Copeland and Deputy Chief Counsel Morris provide insights on pending caseloads including 750+ conservation easement cases and 1,700+ micro captive cases. The panel discusses organizational restructuring at Chief Counsel and the implementation of limited entry of appearance rules.

This panel explores how psychological conditions like depression, PTSD, and OCD affect tax compliance and enforcement outcomes. Practitioners learn strategies for client communication, obtaining reasonable accommodations, and using expert psychiatric evaluations to support penalty relief.

The panel provides practical guidance on leveraging the IRS FOIA library and making effective document requests. Attendees learn about response timeframes, key exemptions including Section 6103, and strategies for appeals and litigation when responses prove inadequate.

This session covers critical exceptions to general limitation periods including circumstances eliminating statutes entirely and six-year extensions for substantial omissions. Practitioners gain insights on international information return implications, gift tax adequate disclosure strategies, and NOL considerations.

The panel examines automatic relief under 9100-2 and discretionary relief under 9100-3 for missed regulatory and statutory elections. Attendees learn about documentation requirements, user fees, processing timelines, and alternative remedies including superseding returns.

This comprehensive session addresses IRS penalty assessment trends and emerging legal challenges including the Farhy circuit split on international penalty assessment authority. The panel covers Eighth Amendment excessive fines arguments, supervisory approval defenses, and Jarkesy implications for fraud penalty adjudication.

The Tax Division representative discusses historic leadership changes and the division’s evolving role amid resource constraints. The session addresses increased tax case filings and representation in appeals courts during this dynamic period for agency rulemaking review standards.

IRS Criminal Investigation Chief Guy Ficco and DOJ representatives provide insights on current investigation priorities and enforcement signals. The panel examines how resource constraints may reshape criminal tax enforcement strategies and practitioner expectations going forward.

Director John Hinman presents the Whistleblower Program Improvement Plan focused on increasing high-value claims and expediting awards. The session covers what makes effective whistleblower submissions and recent court decisions shaping this practice area.